1. Who We Are

KEYS Empowers, Inc. operates the KEYS MST (Multisystemic Therapy) program — an evidence-based, community-based treatment program serving youth and families across Maryland under contracts with the Department of Juvenile Services (DJS) and the Department of Social Services (DSS).

KEYS Empowers, Inc. — MST Program
2519 N Charles Street, Suite 102
Baltimore, MD 21218
Phone: (443) 348-9402
Email: info@keysmst.com
Website: keysmst.com

This Privacy Policy explains how we collect, use, protect, and share information when you visit our website, contact us, or participate in our program.

2. Information We Collect

We may collect the following types of information:

• Contact information — name, phone number, email address, and mailing address when you submit a form, make a referral, or reach out to us
• Referral and intake information — youth and family demographic data, referring agency details, and program eligibility information
• Clinical and treatment information — protected health information (PHI) collected during the course of MST services, including assessments, progress notes, and treatment records
• Substance use disorder (SUD) records — where applicable, information related to SUD diagnosis, treatment, or referral, subject to 42 CFR Part 2 protections
• Communications — messages, emails, phone call notes, and text messages sent to or from our program
• Website data — browser type, pages visited, and general usage data collected automatically when you visit keysmst.com

3. How We Use Your Information

We use the information we collect to:

• Deliver, coordinate, and document MST treatment services
• Process referrals and conduct intake assessments
• Communicate with families, caregivers, and referring agencies (DJS, DSS caseworkers, schools)
• Send appointment reminders, program updates, treatment summaries, and resource information
• Fulfill reporting obligations under our DJS and DSS contracts and Maryland state law
• Conduct quality assurance and program fidelity monitoring (including TAM-R surveys)
• Train staff and maintain professional standards
• Improve our website and program communications

4. HIPAA & Protected Health Information

KEYS MST is a HIPAA covered entity. Any protected health information (PHI) we collect in connection with treatment services is governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and our Notice of Privacy Practices, which is provided to all clients at intake.

Under HIPAA, you have the right to:

• Request and receive a copy of your treatment records
• Request corrections to inaccurate or incomplete information
• Request restrictions on certain uses or disclosures
• Receive an accounting of disclosures made outside the MST treatment team
• File a complaint with our Privacy Officer or with the HHS Office for Civil Rights without retaliation

To exercise any of these rights, contact our Privacy Officer at info@keysmst.com or (443) 348-9402.

5. 42 CFR Part 2 — Substance Use Disorder Records

To the extent KEYS MST creates or maintains records related to substance use disorder (SUD) diagnosis, treatment, or referral, those records receive heightened protection under 42 CFR Part 2 — a federal regulation that is more restrictive than HIPAA in several respects.

SUD records may not be disclosed without the client’s specific written consent except in limited circumstances permitted by law (such as a medical emergency or a valid court order). A single written consent may cover all future uses and disclosures for treatment, payment, and healthcare operations, and may be revoked at any time.

As required by the 2024 Part 2 Final Rule (compliance date February 16, 2026), our Notice of Privacy Practices reflects the updated alignment between HIPAA and 42 CFR Part 2 protections. For more information, contact us directly.

6. SMS & Text Message Communications

If you choose to opt in to receive text messages from KEYS MST through our KEYs MST Text Updates program, the following applies:

• No mobile opt-in data will be shared with third parties or affiliates for marketing or promotional purposes — ever
• Message frequency varies based on your program status and activity
• Message and data rates may apply depending on your mobile carrier and plan
• Reply STOP at any time to unsubscribe immediately
• Reply HELP or email info@keysmst.com for assistance
• Consent to SMS is not a condition of receiving MST services
• SMS is not a secure channel — never send protected health information or sensitive personal information by text message

For the full program terms, see our Terms & Conditions.

7. How We Share Information

We share information only as follows:

• MST Treatment Team — within the internal team (therapist, supervisor, consultant) for coordinated care and clinical supervision
• Referring Agencies — with DJS caseworkers, DSS workers, and other referring entities as required by contract, court order, or with appropriate client authorization
• Psychiatric and Healthcare Providers — with authorized external providers for coordinated mental health and medical care, with client consent
• Schools and Community Partners — only with a signed Release of Information (ROI) from the parent or guardian
• Technology Service Providers — with vendors operating our electronic health record, case management portal, and communication platforms, under appropriate data use and business associate agreements
• Legal and Safety Requirements — when required by court order, subpoena, applicable law, mandated reporting obligations, or to prevent imminent harm

We do not sell, rent, or trade personal information. We do not share mobile opt-in data with any third party for any marketing purpose.

8. Cookies & Website Data

Our website (keysmst.com) may use cookies and similar technologies to support site functionality and analyze traffic. This may include:

• Session cookies that maintain your browsing session
• Analytics tools to understand how visitors interact with our pages
• The GoHighLevel / LeadConnector chat widget embedded on our site, which operates under GoHighLevel’s own privacy practices in addition to this policy

You can manage or disable cookies in your browser settings. Disabling cookies may affect some site features. We do not use tracking cookies for advertising or retargeting purposes.

9. Your Rights

Depending on your relationship with KEYS MST, you may have the following rights:

• Access — request a copy of the information we hold about you or your youth
• Correction — request that inaccurate or incomplete information be corrected
• Restriction — request limits on how we use your information in certain circumstances
• Revocation — revoke previously given consent for certain uses or disclosures (in writing)
• Complaint — file a complaint with our Privacy Officer at info@keysmst.com or directly with HHS OCR at hhs.gov/ocr/complaints

KEYS MST will never retaliate against you for exercising any privacy right.

10. Data Security

We implement administrative, physical, and technical safeguards consistent with HIPAA Security Rule requirements to protect your information. These include access controls, encryption of electronic PHI in transit and at rest, workforce training, and regular security reviews.

If you believe your information has been compromised, please contact us immediately at info@keysmst.com or (443) 348-9402.

11. Children’s Privacy

KEYS MST serves youth under the age of 18 as the core of our clinical mission. Clinical information about minors is collected only with appropriate parental or guardian consent as part of the intake and treatment process, and is governed by our HIPAA Notice of Privacy Practices, 42 CFR Part 2 (where applicable), and Maryland state law.

Our website is not designed to collect personal information from children outside of the formal program intake process. We do not knowingly collect personal information from minors through the website itself.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or applicable law. When we make material changes, we will update the “Last Updated” date at the top of this page. We encourage you to review this policy periodically. Continued use of our website or services after changes are posted constitutes your acceptance of the updated policy.